New Zealand Big Game Fishing Council
PO Box 93
Whangarei
Phone: 09 433 9648
Fax: 09 433 9640
Email: nzbgfc@ihug.co.nz
Website: www.fishing.net.nz
Patron: R C Dinsdale
President: J A Romeril
Secretary: R T Nelson

14 January 2003

The Conservator
Bay of Plenty Conservancy Office
PO Box 1146
ROTORUA

Dear Sir/Madam

Please accept this submission from the NZ Big Game Fishing Council on the Te Paepae Aotea (Volkner Rocks) Marine Reserve Proposal.

Introduction
The NZBGFC represents in excess of 33,000 members from 59 clubs spread throughout NZ including 14 within and around the Bay of Plenty district (about 45% of individual club members). As the parent body of the 59 clubs we have articles in our constitution, which concern the promotion of protection and preservation of the fish species we target and their food source within NZ surrounding waters. We have a long history since our formation in 1957 of continual dialogue with Commercial fishers, the Ministry of Fisheries (its predecessors) and the Minister on matters pertaining to this specific article. We have made a significant contribution to improving the management of kingfish in New Zealand (lobbying for the introduction of recreational bag limits, size limits and removal of size limit exemption for trawlers) as it is the one large pelagic species available to our members year round.

We oppose the Te Paepae Aotea (Volkner Rocks) Marine Reserve Proposal
The Department of Conservation and the Steering Committee have not recognised the importance of the south ridge as a national and international “Mecca” for kingfish fishers therefore we are totally opposed to any Marine Reserve at the Volkner Rocks.

The Importance of Kingfish
Recreational fishers recognise the kingfish fishery in the Volkner Rocks area as being probably the best in New Zealand – consistently producing large fish for the last 20 years. New Zealand has almost all of the World records for Southern yellowtail kingfish (Seriola lalandi) caught on rod and reel, therefore the Volkner Rocks area has arguably the best kingfish fishery in the World. Fishers from all over New Zealand and indeed all around the world come to fish the Volkners and White Island. Most of what they catch is tagged and released for research purposes.

To state that some recreational fishers “will be inconvenienced” clearly shows that after three years DoC and the steering committee still don’t know (or don’t care) why the Volkner Rocks is special. The ridge that runs to the south of Volkner Rocks rises out of deep water and the current accelerates as it sweeps over and around it. Kingfish hold in the current in front or above the ridge but once hooked are soon taken over the ridge into deep water where the powerful fish can’t reach the bottom. This area is the top kingfish location according to Ministry of Fisheries tagging programme records. To describe the closure of this fishery in such an off-hand way as an “inconvenience” to recreational fishers we feel is dismissive.

DoC and the steering committee would take this fishery away rather than face the slight inconvenience of having marine reserve boundaries that weren’t a nice round shape, 1 mile from all islands.

Where is the Threat?
The reason this proposal must be rejected is that none of the significant features listed in the justification are affected by the current kingfish fishery. Kicking out the New Zealanders and international tourists that pay good money for the Volkner Rocks fishing experience will not enhance the distinctive and unique features described in section 6.1. Fishing for kingfish will not disturb the spectacular underwater scenery, of the clear water, or the rare invertebrate species such as sponges and crabs, starfish and urchin. The smaller marine fishers of the Volkners might actually benefit from having a few less kingfish to feed.

The Volkner Rocks are a long way offshore and are very exposed. These factors already offer them considerable protection from fishing pressure.

The authors of this proposal clearly make the assumption that all fishing is bad for biodiversity and there will be a “recovery” phase once fishing has stopped. However there is absolutely no evidence of damage caused by fishing for kingfish on any of the “special features” or species the authors want to protect. Where is the current threat? Where is the Justification for Plucking Out one of the jewels in New Zealand recreational fishing and putting it off limits forever?

New Zealand recreational fishers affiliated to the NZBGFC often rely on the hard working volunteers elected to their club committees to inform them of issues that affect them. The submission period over the traditional NZ summer holiday break has made it difficult for committees to meet and newsletters to reach club members. Most will realise too late that they could have had their say. If the process is perceived as unfair it will only galvanise opposition to future reserves.

Purpose of the Act
The authors of the Volkner Rock marine reserve proposal have misquoted the purpose of the Marine Reserves Act (1971). They have totally omitted the scientific study of marine life. Section 3.1 reads:
“It is hereby declared that the provisions of this Act shall have effect for the purpose of preserving, as marine reserves for the scientific study of marine life, areas of New Zealand …”

Whereas the authors only quote what type of areas may be preserved for scientific study, Section 3.1 continues:
“…that contain underwater scenery, natural features, or marine life, of such distinctive quality, or so typical, or beautiful, or unique, that their continued preservation is in the national interest.”

Surely the Volkner Rocks proposal needs to be consistent with the primary purpose of the Marine Reserves Act (1971), which is scientific study. Far from it the establishment of a marine reserve will severely constrain existing Ministry of Fisheries funded research into the age, growth rate and natural mortality of New Zealand kingfish.

Over 1000 kingfish have been tagged and released at the Volkner Rocks over the last 20 years as part of the Ministry of Fisheries Cooperative Tagging Programme (currently MFish project PEL2000/01). One of the key objectives of the tagging policy is to measure and tag fish larger than 1 metre long to help establish the growth rate of larger fish.

Over the last 2 years more than 170 kingfish have been tagged at Volkner Rocks with 95% of these measured before release - 72% (or 123 kingfish) were longer than 1 metre. There are few areas in New Zealand where large kingfish are tagged in these numbers.

Over the last 2 years for all of New Zealand 433 kingfish greater than 1 metre have been measured and released so 28% of this total were tagged at the Volkner Rocks.

Recently another kingfish research project (Ministry of Fisheries project KIN2000/01) has begun collecting otolith samples and length data from Bay of Plenty charter boat skippers. To date about 90% of length data has come from recreational fishers from Volkner Rocks and White Island and nearly 50% of the otoliths (the ear bone used in estimating the age of fish) come from this area. Research into age and growth of kingfish will ultimately be used to determine natural mortality and therefore the productivity of the kingfish fishery in New Zealand, rather than using estimates for a Californian sub-species.

There is no-doubt that existing and future research on kingfish will be detrimentally affected by the Volkner Rock Marine Reserve proposal. This is contrary to the purpose of the Marine Reserve Act (1971), which is to promote scientific study. Again, where is the justification for threatening these projects? On the other hand the presence of the Kingfish fishery would in no way hinder studies into rare invertebrates, reef communities, or geological features at the Volkner Rocks.

Policy Disagreement
The foundation block of NZBGFC policy is ensuring we have continued access to quality fishing opportunities for the future, so that our children and their children will be able to enjoy the simple pleasure of recreational fishing. Yes there needs to be considered and careful management to achieve this but total closure of nationally significant recreational fishing locations such as the Volkner Rocks will be strongly opposed.

The proposal the Volkner Rocks as isolated regions needing special help to preserve the abundant and variety of marine life that exists there. The NZBGFC has seen similar proposals and arguments for a number of other offshore islands. We believe this to be an active part of a Department of Conservation plan to utilise the Marine Reserve Act 1971 to return the majority of off shore islands and prime coastal regions to marine reserves. Using as its mandate the act of conserving and protecting the natural resource. The NZBGFC has the same conservation mandate from its members but strongly differs on how this should be implemented.

The preservation of invertebrate fauna should not be used as a justification for closing such an important area to recreational fishers.

Economic Considerations
Recreational fishing is a major generator of economic turnover. An independent report on the value of recreational fishing (project REC9801) released in September 1999 by MFish showed that annual recurrent expenditure by recreational fishers to be $973 million on just five of the most popular fish species. These are Snapper, Kingfish, Blue Cod, Kahawai and rock lobster. Recurrent expenditure included items of fuel, accommodation, travel, tackle, charters and bait and makes no allowance for the purchase of capital expenditure items such as Boats and fishing equipment. The Bay of plenty is well known for its fishing especially in the area being considered for reserve status. One third of the council’s membership come from within this region and considerable number of outer province and international angler’s travel into the region for the excellent year round fishing it provides. Without having the specific figure available it would be a safe bet to conclude a that a healthy proportion of the near Billion-dollar turnover is spent in this region.

Since that time new estimates of the number of recreational fishers in New Zealand have called into question the proportion (10%) used in the 1996 recreational harvest survey and the economic report. The new estimate (25% or more) is believed to be more accurate. This would vastly increase the annual turnover of recurrent expenditure calculated.

The committee should be aware that a radical change in access by recreational fishers to kingfish in the proposed reserve area would have a financial bearing on the local community. Drift fishing on the south ridge can be successful in all but the worst weather. The region already attracts non-extractive dive parties but the Volkner Rocks are a difficult area to dive. Strong currents and exposure to wind and waves from every point of the compass will severely restrict the number of dividable days. The creating of a large reserve is unlikely to rapidly increase the growth of this activity and certainly not to the point where it will replace the financial turnover presently generated by recreational fishers.

Uniqueness of the Volkner Rocks
The items identified on page one of your proposal document as being unique, deserving of special treatment are mainly of the type that are not in danger from normal recreational line fishing. Rare sponges, lace coral, kelp forests, anemones and small plants and animals are not what fishers target or even disturb by their process of fishing for their preferred species. The non-extracting diving experience offered by unique circumstances of geography, ocean currents and volcanic activity are not threaten by recreational line fishing. The real threat to theses species is from boats that have to anchor such as dive boats.

Summary
The NZBGFC, on behalf of its 33,000 members, submit that the kingfish fishery at the Volkner Rocks is socially, culturally and economically important to New Zealand. It should be recognised as such.

Nowhere in the Te Paepae Aotea (Volkner Rocks) Marine Reserve proposal has the closure of this fishery been justified. Nor has any attempt been made to explain how the kingfish fishery actually affects any of the special features that DOC and the steering committee are trying to preserve.

There are two important research projects investigating kingfish growth that require length data, release and recapture or otoliths from large kingfish such as those caught at the Volkner Rocks. Closing this area to fishing will be detrimental to current and future scientific research, therefore this proposal is contrary to the purpose of the Marine Reserves Act (1971).

Our response to this proposal has been limited because it fell over the Christmas New Year period. We reserve the right to add to this submission over the next month.

Yours sincerely

Jeff Romeril
PRESIDENT